Transfer-pricing treatment of ITeS margins excludes pass-through tax recoveries and separate delayed-receivables interest after working-capital adjust...
Capacity-utilisation adjustments under TNMM can neutralise substantiated COVID-related idle costs where underutilisation materially affects profitabil...
TNMM functional comparability requires excluding rice manufacturers from a pure Basmati rice trader's benchmark and recognising operating export recei...
Working-capital adjustment subsumes delayed-receivable effects in TNMM benchmarking of captive software-development services, avoiding separate notion...
Transfer-pricing comparability requires exclusion of financially illogical super-profit comparables and correction of unsupported annual-report and ma...
Charitable character assessment preserves Section 80G approval despite inclusive spiritual teachings and incidental religious expenditure within the s...
Penalty proceedings for cash-loan acceptance require assessment proceedings and recorded Assessing Officer satisfaction; absent these, the proceedings...
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The HC upheld that the adjudicating authority shall follow binding appellate precedents of the jurisdictional appellate forum; orders of an Appellate Collector and of the Tribunal bind subordinate Assistant Collectors within their respective jurisdictions. Applying the doctrine of judicial discipline, the HC directed that subordinate authorities must implement higher appellate orders notwithstanding departmental disagreement, unless the order's operation has been lawfully stayed by a competent court. Noncompliance would constitute undue harassment and administrative chaos. Having regard to these conclusions and the parties' submissions, the court issued a notice returnable on 2.9.2025 and permitted direct service by e-mail.
The HC upheld that the adjudicating authority shall follow binding appellate precedents of the jurisdictional appellate forum; orders of an Appellate Collector and of the Tribunal bind subordinate Assistant Collectors within their respective jurisdictions. Applying the doctrine of judicial discipline, the HC directed that subordinate authorities must implement higher appellate orders notwithstanding departmental disagreement, unless the order's operation has been lawfully stayed by a competent court. Noncompliance would constitute undue harassment and administrative chaos. Having regard to these conclusions and the parties' submissions, the court issued a notice returnable on 2.9.2025 and permitted direct service by e-mail.
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